EFPIA Disclosure Requirements and Template, Explained

The EFPIA Code of Practice requires member companies to publish, every year, the transfers of value (ToVs) they make to healthcare professionals (HCPs), healthcare organisations (HCOs) and patient organisations. National industry associations transpose these rules into their own codes, so the details vary by country, but the core requirements are the same. This guide summarises them from the EFPIA Code of Practice 2026.

Where the rules sit

In the 2026 Code, disclosure is Chapter 5, “Disclosure of ToVs from Member Companies”. Article 22 sets common requirements, Article 23 covers HCPs and HCOs, and Article 24 covers patient organisations. If your SOPs cite article numbers from an earlier edition, check them against the 2026 text.

When: timing and retention

• Disclosures are made annually, and each reporting period covers a full calendar year.
• They must be made within six months after the end of the reporting period.
• The 2026 Code sets a common publication window from 20 to 30 June each year at the latest.
• Disclosed information must stay public for at least three years, subject to shorter national law or the data protection basis ceasing to apply.
• Records must be kept for at least five years after the end of the reporting period.

What: categories of transfers of value

For HCOs, the categories are donations and grants, contributions to costs related to events (registration fees, sponsorship agreements, and travel and accommodation), and fees for service and consultancy. For HCPs, they are contributions to costs related to events and fees for service and consultancy. Fees and related expenses are disclosed as two separate amounts.

Research and development ToVs are disclosed in aggregate.

Individual or aggregate disclosure

ToVs must be disclosed on an individual basis. Where individual disclosure is not possible for legal reasons, they are disclosed in aggregate, showing the number of recipients, in absolute terms and as a percentage of all recipients, and the aggregate amount. Under the GDPR, naming an HCP needs a lawful basis; our article on GDPR and transparency reporting covers consent and legitimate interests.

Where: templates and platforms

Companies use the standard disclosure templates in Annex A of the Code, which is binding: one for HCP/HCO ToVs and one for patient organisation ToVs. Within a country, only one template applies. Disclosure is made on the company’s website or on a central platform, such as one provided by a government, regulator, professional body or member association. In the UK, the central platform is Disclosure UK; see our guide to how Disclosure UK works.

The methodology note

Each company must publish a note summarising the methodologies it used to prepare its disclosures. For HCP/HCO disclosures, the note must follow the mandatory structure in Annex B, which applies at the latest for the 2026 disclosure of 2025 ToVs. The headings are:

1. Definitions
2. Disclosure scope
3. Specific considerations
4. Data protection legal basis, including consent collection or legitimate interest (with the balancing test and right to object)
5. Form of disclosure, including date of publication, platform, language, currency, whether VAT is included, and calculation rules
6. Additional information

Annex B also requires reports to be machine-readable, for example a searchable PDF, available online and downloadable, and searchable by recipient name. Our free methodology note template follows this structure.

Practical checklist

• Map every ToV source, including agencies and affiliates, to the right category.
• Decide and document the data protection basis for naming HCPs.
• Separate fees from expenses and R&D from other ToVs in your data.
• Draft the methodology note in the Annex B structure.
• Plan publication inside the 20–30 June window, and check national deadlines, which can be earlier. See our disclosure deadlines by country.

This article summarises the EFPIA Code of Practice 2026. National codes and laws may differ; it is not legal advice.